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#1611908 - 10/03/11 10:33 PM CTR issues with new ATM
mzachau, CRCM Offline
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mzachau, CRCM
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San Francisco
We are in the process of purchasing and implementing a new ATM to meet ADA laws. Our old ATM did not accept deposits, however the new ATM will.

Our vendor is telling us that it will cost $15,000+ to program the ATM software to identify the difference between cash and check deposits. If no programming was to be performed, we would not be able to determine whether the deposit was cash, check, or combination of both.

Is there an exemption under BSA that would not require us to have an ATM that could identify cash transactions for CTR reporting purposes?

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#1611943 - 10/04/11 01:08 PM Re: CTR issues with new ATM mzachau, CRCM
Elwood P. Dowd Offline
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There is no legal requirement that a bank must have a system for aggregating cash transactions. There never has been. However, it would be nigh on to impossible to audit BSA compliance in the absence of such a system, so they are a regulatory expectation at least.

Regardless, no bank has a "perfect" system that aggregates cash "by or on behalf of the same person" at every possible portal. As no system is required, there are no "exemptions" for the portals that are missed in one system compared to another.

What might be helpful to you is to hear from other bankers whose ATMs cannot recognize the composition of a deposit as to whether their reviewers thought that was a significant shortcoming. To sit through such a criticism, I would have to hear someone pointing out instances where the amount of currency we missed was significant.
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#1611948 - 10/04/11 01:24 PM Re: CTR issues with new ATM Elwood P. Dowd
edAudit Offline
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How are you going to process the deposit transaction?

If by envelope, the cash would be processed by the teller system and cash will show as regular cash.
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#1611951 - 10/04/11 01:29 PM Re: CTR issues with new ATM edAudit
ACBbank Offline
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Originally Posted By: EdAudit
How are you going to process the deposit transaction?

If by envelope, the cash would be processed by the teller system and cash will show as regular cash.


That's how we do it.
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#1612095 - 10/04/11 03:47 PM Re: CTR issues with new ATM ACBbank
John Burnett Offline
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And that's how we did it 10 years ago. We had branches notify us whenever an ATM deposit included more than $500 cash. It was pretty rare (ATM deposits were about 1% of our ATM transaction counts). When we got a report, we checked to see what else the customer did that day.
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#1612218 - 10/04/11 05:26 PM Re: CTR issues with new ATM John Burnett
mzachau, CRCM Offline
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mzachau, CRCM
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San Francisco
Thank you all for your comments and recommendations. Envelopes will not be used when depositing cash and/or checks into the ATM.

Our expectation is that deposits at the ATM will be very rare and that is why management is asking if there are alternatives. My concern though is that even if someone were to deposit over $10K in cash at the ATM, the system would not differentiate between cash or check and we would just see one big deposit. Even though this will probably "never" happen, examiners are not in a "understanding logic" mindset!

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#1612494 - 10/04/11 09:10 PM Re: CTR issues with new ATM mzachau, CRCM
ACBbank Offline
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New York City
Ok, I'm confused. CTR issues aside, if someone deposits cash into an ATM and you can't tell its cash, how can it be credited appropriately to the account?
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#1613882 - 10/07/11 05:53 PM Re: CTR issues with new ATM ACBbank
BetsyS Offline
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The deposit is actually an EFT credit initiated by the customer at the ATM with their card & PIN. They key in the dollar amount and select the account to be credited if they have access to more than one account with their card. Depending on the ATM, typically they then place the cash or checks into an envelope and deposit it into the ATM.

On the back end, the credit is settled with some type of sequence number which can be matched to the sequence number on the envelope deposited in the ATM so the transaction can be verified. Our ATM also prints the dollar amount keyed in and the cardholder's number on the envelope. And yes, they don't always match and we have to make an adjustment to the cardholder's account.
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#1613983 - 10/07/11 07:10 PM Re: CTR issues with new ATM BetsyS
John Burnett Offline
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I think the point here is that, eventually, your bank knows the contents of the deposit and whether and how much cash was involved. That knowledge needs to make it from the ATM deposit settlement area (a branch or a central point that opens and processes the envelopes) to whoever aggregates cash activity to determine whether a CTR is warranted.
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